Beginning for payments made in calendar 2008, American Express will request information regarding political contributions from trade associations, entities organized under section 501(c) 4 of the Code, and other tax exempt organizations that engage in non-deductible lobbying and political expenditures under Code section 162(e). For any such organization that receives in excess of $50,000 during the calendar year from the Company, American Express will request that the organization identify the portion of American Express’ payments used in connection with participation or intervention in a political campaign on behalf of (or in opposition to) any ballot initiative or candidate for public office, as defined under Subsection 162(e)(1)(B) of the Code. American Express will include in its political contributions report on its website any responses American Express receives to such requests.

If I were in American Express’s shoes, and making contributions to these organizations, I think I would be insisting on responses.

General Dynamics participates in the U.S. political process when it is in the best interests of its shareholders, businesses and employees to do so. Participation in this process ensures that the company’s interests as a leading member of the defense and aerospace industries, as well as a large employer, are well represented.

The company makes contributions on a limited basis to 501(c)(4) organizations as well as to state and local candidates, where permissible and in accordance with all laws and regulations. On occasion, the company provides funding for organizations that function under Section 527 of the Internal Revenue Code.

The whole thing makes interesting reading. Here’s the Center for Responsive Politics’ profile of the company’s PAC and individual donor contributions. No information is available on the 501(c)4 contributions ($103,600 in 2006), because those groups don’t have to disclose their donors. You can find General Dynamics’ 527 contributions by clicking here, choose contributor name from the right hand column, click “next step,” then type “General Dynamics” into the search box.

The forms, required by the Foreign Agents Registration Act, are filed with the Department of Justice every six months. The most recent disclosure states that the firm received $990,000 in lobbing fees and another $3,000 in expenses from the Saudi government to lobby on trade issues from May to November 2007, but does not cite any in-person meetings, phone conversations or e-mails with any executive branch official, member of Congress or staff. According to the May 2007 filing there was only one teleconference on March 26, two weeks after Loeffler joined McCain’s campaign. FARA requires lobbyists of foreign governments to disclose all such contacts in the biannual filings with the Department of Justice.

According to the November 2007, disclosure forms signed by Tom Loeffler, the firm “provided services related to interaction between foreign principal and Members of Congress, congressional staff, officials in the Executive Branch and the World Trade Organization.” Although it is possible that there were no reportable contacts during the time, the forms do not explicitly say so.

By contrast, disclosure forms filed in 2006 by the Loeffler Group in May and November detail meetings with members of Congress, including one with McCain on May 17, 2006. The filings also show that in 2006, Tom Loeffler had facilitated meetings between then Saudi Ambassador Price Turki Al-Faisal and Sen. Arlen Specter, R-Pa., and Sen. Pete Domenici, R-N.M., to discuss “U.S.-Saudi relations.” The November 2006, disclosure shows that meetings were convened between Tom Loeffler and Rep. Jim Kolbe, R-Ariz., Rep. Roy Blunt, R-Mo., and Rep. Joe Barton, R-Texas, in June.

The Loeffler Group has received close to $15 million since 2003 when they began to lobby for the Saudi government. In 2006, the year after Saudi Arabia entered the WTO group of countries, the Loeffler Group received more than $7million from the Saudis in lobbying fees, FARA documents show.The firm declined to comment on any of their lobbying disclosure filings.

In addition to the Saudis, the Loeffler Group’s other foreign clients include the Hong Kong Economic and Trade Office, a government agency that hired the firm to lobby on trade issues including international trade policy, U.S.-China trade relationship and the WTO.

Loeffler, who represented Texas as a member of the House of Representatives from 1978 to 1986, serves as the general co-chair of McCain’s campaign. Susan Nelson, another Loeffler Group employee who also lobbied on behalf of Saudi government, later left the firm to take up a position with McCain as campaign finance director.

Ties between the McCain camp and the Loeffler Group run deeper: Employees of the lobbying firm have given more than $13,000 to the McCain presidential campaign, with Tom Loeffler making a maximum primary contribution of $2300 in June 2007.

Last week, Mark Penn, a lobbyist with Penn, Schoen & Berland, stepped down as top strategist for Sen. Hillary Clinton’s, D-N.Y. He resigned after news reports that Penn, a lobbyist for the government of Colombia advocated for trade policies that Clinton opposed. Though Penn tried to distance himself from his firm’s advocacy to the Colombian government, which led them to drop their contract with Penn’s firm, it still cost Penn his job.

In Loeffler’s case, the filings don’t list any meetings, though they do describe ongoing advocacy for the Saudi government and show hefty fees as well.

Loeffler has been involved in some lobbying efforts while working for the McCain campaign. According to an Associated Press report from earlier this year, he lobbied on behalf of European Aeronautic Defense and Space Co.– the parent company of Airbus – while serving as one of McCain’s chief advisers. One of the key issues that was lobbied on by EADS was the aerial refueling contract. In the past couple of years, McCain has been nudging the Pentagon to ensure that their bidding procedures do not leave out Airbus.

McCain’s campaign did not respond to phone and e-mail contacts requesting comment.

The new Iraqi government was afraid that those harmed by the previous regime, including prisoners of war from the first Gulf War or people affected by acts committed during Saddam Hussein’s rule, would seek compensation by suing Iraq, seeking assets currently in the United Sates. The government of Iraq raised objections to Section 1083 of the bill, which “strengthened the ability of victims of the brutality of Saddam Hussein to seek compensation,” according to a statement put out by the Speaker’s office. Later in January, Congress introduced new language that waived the applicability of this section for Iraq under the assumption that it would promote Iraqi reconstruction and continue the democratic process in Iraq.

The lobbyist filing the FARA disclosure was a Maggs & McDermott partner, Timothy B. Mills, who has been with the firm since February 2006.The nondescript firm in Brielle, NJ, has been in business since November 2002 and had been known as DiCroce & Maggs LLC before then. No one from the firm had ever registered to lobby before, either with the state of New Jersey or the U.S. Congress. Their first lobbying job was to represent the Iraqi government on an all important section of the defense bill.

Maggs & McDermott doesn’t even have its own Web site, but in an e-mail exchange Mills wrote that the firm’s areas of operations included, “foreign sovereign defense of claims made in U.S. courts by private plaintiffs; international disputes; public contract law disputes and Privacy Act litigation.” The e-mail also said that Mills had represented the Government of Iraq in Foreign Sovereign Immunities litigation since June 2004. Maggs & McDermott started their D.C. operations after Mills joined their firm a year ago, heading their DC offices.

Before working with Maggs & McDermott, Mills was a partner at the prominent Washington, D.C. lobbying firm, Patton Boggs. According to court documents, Mills has been lead counsel or co-counsel on at least three civil litigation cases since 2002 filed with federal courts in Washington, D.C. Mills is also the President of the American Chamber of Commerce in Iraq and was on the team of counsel representing the Bush-Cheney campaign during the 2000 Florida recount, according to this profile on the Republican National lawyers Association website.

But what’s unclear is why Mills made the move from Patton Boggs to a non-descript New Jersey firm with no history of taking on crucial international cases and no history of lobbying. Mills declined to comment on his decision to move to the smaller firm.

The FARA disclosure forms state that the point of contact in Iraq is the National Security Advisor for the Government of Iraq. In the section describing all political activities, the forms states, “communications with members of the Executive and Legislative Branches of the U.S. Government to urge non-implementation as to Iraq of the amendments to the U.S. Foreign Sovereign Immunities Act…”

Under FARA regulations, a lobbyist representing any foreign country and some foreign government-sponsored entities must disclose various meeting, phone calls and other communication as part of the disclosure. Those disclosures for this particular lobbying effort are not available yet, since they have to be disclosed only after six months after the initial registration (linked above) is filed with the FARA office in the Department of Justice.

The University of Alabama employs a pair of lobbying firms — Van Scoyoc Associates (we encountered them in earmark #8 and earmark #9) and Smith, Hinaman & Associates. Interesting to note that while Van Scoyoc Associates monitors all appropriations bills (according to page two of the linked filing) they don’t explicitly mention the Labor, HHS, Education bill. Bonner has received $18,736 in contributions from the firm’s employees and PAC since 2002.

Meanwhile, employees of Smith, Hinaman & Associates have contributed $11,500 to Bonner from March 2002 to Sept. 2005. They don’t mention a specific bill, but were seeking “funding for robotics/imaging research.”

Patton Boggs, one of the bigger Washington lobbying firms, lobbies for Team Focus; a quick check of Open Secrets shows just $550 in contributions to Bonner from employees of the firm–all in 2002.

I looked up Team Focus’ 990s on Guidestar to get a list of directors and executives to see if any of them had contributed to Bonner’s campaign (there was one match, for $500, in 2007, from Michael Gottfried, the organization’s founder and CEO) and came across this reference to Patton Boggs (click on the image to see it larger, click again to see it full-size):

Actually, “fundraising” does sort of jibe with Patton Boggs disclosed when it registered to lobby, effective Feb. 14, 2005:

(Again, click the image to see it larger). “Seek federal funding” is pretty close to fundraising. In their 2007 mid-year disclosure, Patton Boggs said they were lobbying on Team Focus’s behalf for “Funding for juvenile justice and education programs. FY 2008 Commerce/Justice/Science Appropriations.”

Now, here’s a cautionary tale about why you should always cross reference documents whenever possible. Team Focus’ 990s don’t disclose spending any money on federal lobbyists. Here’s the relevant section from their 2007 IRS filing:

And on Schedule A, Part III, Question 1, which asks, “During the year, has the organization attempted to influence national, state, or local legislation, including any attempt to influence public opinion on a legislative matter or referendum? If “Yes,” enter the total expenses paid or incurred in connection with the lobbying activities?” with a no…

I called Team Focus, and talked to Cathy Nabors, their executive assistant, who seemed genuinely surprised that their man at Patton Boggs, Thomas C. Downs, had done any lobbying. Brandy Morgan, who works at Hieronymous, Gaillard & Jones LLC, the accounting firm that prepared the 990 for Team Focus, echoed that reaction, and said that the she understood from Nabors that Downs was helping prepare paperwork in connection with some federal grant applications (which would not be lobbying).

Some idle speculation: It’s entirely possible that Downs filed the lobbying disclosures out of an excess of caution even though he didn’t actually lobby (although the disclosures say that he contacted the House and Senate–worth noting that he turns up in Open Secrets’ Revolving Door database as a former congressional staffer); it’s also possible that there was a simple miscommunication somewhere along the line.

I called Downs and left a message for him.

By the way, and just to be clear — this was just an oddity I ran across with conflicting documents. One set is most likely inaccurate, and I’m just curious to find out which one.

It doesn’t appear that the State of Alabama or the Alabama Department of Conservation and Natural Resources lobbied for the earmark.

The Mobile Regional Airport Authority employed Van Scoyoc Associates to lobby Congress; according to page two of their 2007 mid-year report, Van Scoyoc lobbied on the “Transportation, Treasury, Housing & Urban Development…” appropriations, including “airport infrastructure and service issues.”

As noted in this post, the employees and the PAC of Van Scoyoc Associates have contributed $18,736 to Bonner’s campaigns since 2002.

The Mobile County Commission had Washington representation — the lobbying firm Van Scoyoc Associates. They lobbied on the “Commerce, Justice, Science and Related Agencies Appropriations Act, FY 2008,” according to page 3 of this disclosure report.

Van Scoyoc employees have contributed $16,250 to Rep. Bonner’s campaigns between April 2002 and November 2007, according to Open Secrets. Van Scoyoc also has a PAC, which contributed an additional $1,472 in 2006 and $994 in 2004. For those scoring at home, that’s $18,736 in contributions over the course of Bonner’s congressional career.